My bills are all due, and the babies need shoes, but I'm busted....-Ray Charles, American blues singer, 1963' An oft-used statement in American and Canadian legal writings is that an employer's unilateral termination of a worker is the capital punishment of industrial relations. 2 The employment-at-will rule prevalent in most American states is the antithesis to the law in most European countries, where job security laws abound. This rule permits either the employer or employee to terminate the employment relationship at any time, with or without cause. Domestic legislation in Europe consistently requires the employer not only to show good cause but also to tender statutory notice to a worker who is to be terminated. Moreover, these laws usually require the company to pay the affected worker severance pay, generally gauged by his period of service. The American at-will rule, the absence of statutory severance pay, and the dearth of pre-termination notice are anomalous to worker protections common in Europe. This article will compare and contrast American law with the usual European laws regarding restrictions on employers and rights of employees in termination cases. Part I addresses relevant supranational conventions and treaties that have instigated much domestic employment legislation in Europe. In particular, the Intemational Labor Organization and the European Commission have been significant in this area. Part II has two subsections. First, an elaboration of Irish law exemplifies the myriad of worker protections and management obligations in termination decisions. The second section includes more summary treatment of some other European countries: four pre-2004 European Union member states (Austria,
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